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Case 1:20-cr-00330-PAE Document 217 Filed 04/19/21 Page1of6 Haddon, Morgan and Foreman, P.c Laura A. Menninger HAD DON 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 Fx 303.832.2628 www.hmilaw.com LMenninger@hmfilaw.com MORGAN FOREMAN April 1, 2021 The Hon. Alison J. Nathan United States District Court Judge Southern District of New York 500 Pearl Street New York, NY 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Joint Letter Concerning Redactions to Omnibus Response & Exhibit 11 Dear Judge Nathan: Pursuant to this Court’s Order of March 29, 2021 (Dkt. No. 189), the parties respectfully submit this joint letter concerning redactions to the Omnibus Memorandum in Opposition to the Defendant’s Pre-Trial Motions (“Response’’). Joint Position The parties no longer seek the proposed redactions to pages 118 and 119 of the government’s Response. Ms. Maxwell’s Position Ms. Maxwell seeks to redact from pages 129-134 of the Response and from Exhibit 11 only those portions of her July 22, 2016 deposition as to which Judge Preska ruled: public access to [these] parts of the transcript is outweighed by Ms. Maxwell's countervailing interests in resisting disclosure of the details of her private, intimate relationships with consenting adults. This testimony is, in any case, far afield from the sex trafficking and sexual abuse allegations that were central to the dispute in Giuffre v. Maxwell. Although the prurient interest of some may be left unsatiated as a result, Ms. Maxwell's interest in keeping private the details of her sexual relationships with consenting adults warrants the sealing of those portions of her testimony (and any materials that reference them). DOJ-OGR-00003847